Mathews v. Pyle
In Mathews v. Pyle, 75 Ariz. 76, 251 P.2d 893 (1952), a newspaper sought to inspect certain investigative documents furnished by the Attorney General to the governor.
Then, as now, Arizona's public records statute, former A.C.A. 12-412 (1939), included but did not define "public records" or "other matters." Drawing on other states' common law, however, our supreme court embraced the following three-part definition of "public record:"
- A record "made by a public officer in pursuance of a duty, the immediate purpose of which is to disseminate information to the public, or to serve as a memorial of official transactions for public reference;"
- A record that is required by law to be kept, or necessary to be kept in the discharge of a duty imposed by law or directed by law to serve as a memorial and evidence of something written, said or done; - A written record of transactions of a public officer in his office, which is a convenient and appropriate method of discharging his duties, and is kept by him as such, whether required by express provisions of law or not. Id. at 78-79, 251 P.2d at 895.
The court concluded that the documents received by the Governor in his official capacity were not intended to be classified by the legislature as public records, but they may fall within the classification of "other matters" . . . and therefore subject to inspection by an interested citizen unless they are confidential or of such a nature that it would be against the best interests of the state to permit a disclosure of their contents. Id. at 80, 251 P.2d at 896.